Universal Waste:

Compliance Bulletin
Hazardous Waste
Universal Waste Rule
reviewed/revised June 2003

What are Universal Wastes?
The Universal Waste Rule [Colorado Hazardous Waste Regulations 6 CCR 1007-3 Part 273] includes certain hazardous wastes that are commonly generated by very small to very large non-residential sources such as businesses, government agencies, and schools. Universal wastes are subject to wide spread use, which makes disposal of these hazardous wastes difficult to control. These same wastes are not regulated as hazardous wastes if generated by residential consumers. Residential wastes may be disposed of through a local household chemical waste collection event or facility, recycled, or if these options are not available, disposed of in a municipal solid waste landfill. “Household” includes single-family homes, apartments, hotels and motels, retirement homes, bunkhouses, ranger stations, crew quarters, picnic areas, campgrounds, and day-use recreation areas. Materials included as universal wastes are regulated under the Resource Conservation and Recovery Act (RCRA) and have been required to be handled as hazardous wastes since the early 1980s. In the past, if these wastes were determined to be a hazardous waste, small and large quantity generators of hazardous waste needed to manage them in full compliance with the hazardous waste regulations, including labeling, employee training, manifest requirements, and restrictive time limits. [6 CCR 1007-3 Parts 260 – 268, 99, 100]

The Universal Waste Rule provides an alternative set of reduced management standards that the generator can follow instead of the full hazardous waste requirements. This rule was designed to reduce the regulatory burden on non-residential entities that generate these wastes and to encourage recycling, while at the same time reducing the amount of hazardous waste items illegally sent to municipal solid waste landfills, thus reducing a potential threat to public health and the environment.
The Colorado Hazardous Waste Regulations include the following universal wastes:

  • batteries, found in many common items including electronic equipment, mobile telephones, cameras, computers, and emergency backup lighting. In general, nickel-cadmium, lithium, most button batteries and some alkaline batteries are hazardous wastes when disposed.
  • agricultural pesticides that have been recalled or banned from use, are obsolete, have become damaged, or are no longer needed due to changes in cropping patterns or other factors. Many agricultural pesticides are listed hazardous wastes or exhibit one or more characteristics of hazardous waste.
  • mercury-containing devices with less than 5 kg (about 11 pounds) of mercury per device, such as mercury thermostats, thermometers, blood pressure cuffs, manometers, barometers, gauges and flow regulators, electrical switches and relays, pyrometers, thermocouples and mercury filled vacuum pumps. These devices are generated by medical clinics, hospitals, the electronics industry, small businesses, pipeline monitoring companies, and other industrial operations.
  • aerosol cans containing hazardous wastes, such as paint, brake cleaner or other solvents.
  • mercury-containing lighting wastes, such as fluorescent, high-pressure sodium, mercury vapor and metal halide lamps.
  • electronic devices and components that fail the toxicity test for heavy metals, such as computer monitors, color televisions and circuit boards. The hazardous waste regulations apply only to wastes that are determined to be hazardous waste, either by being a listed hazardous waste and/or by exhibiting one or more characteristics of hazardous waste as defined in State hazardous waste regulations [6 CCR 1007-3 Part 261]. It is the responsibility of the generator of the waste to determine if their wastes are hazardous wastes in order to ensure proper management and disposal. [6 CCR 1007-3 Section 262.11] Wastes from nonresidential sources that are not hazardous may be disposed of in a properly managed municipal solid waste landfill or sent to a legitimate recycler. Landfills and recyclers may impose their own restrictions to regulate incoming wastes in accordance with local rules or company guidelines..Universal Wastes include many:
    • batteries
    • pesticides
    • mercury-containing devices
    • mercury-containing lighting wastes
    • aerosol cans
    • electronic devices and components

    company guidelines. Consult the landfill operator or recycler regarding their requirements. Colorado was not required under federal law to adopt the Universal Waste Rule because the new rule was less stringent than the existing requirements under RCRA. As a RCRA-authorized state, the Colorado Hazardous Waste Commission had to adopt state analogs equivalent to the regulatory requirements of the Federal Rules in order for the Universal Waste Rule to become effective in Colorado. The Colorado Hazardous Waste Commission adopted reduced management practices for these widely generated wastes under the Universal Waste Rule [6 CCR 1007-3 Part 273] for certain pesticides, mercury thermostats and batteries in 1995. Aerosol cans containing hazardous waste were added to the rule in 1996, and mercury-containing lighting wastes were added in 1999.
    The provision for mercury thermostats was expanded to include other mercury-containing devices, such as thermometers, in 2000. Electronic devices and components that fail the toxicity characteristic test for heavy metals were added to the universal waste rule effective July 31, 2001.

    Why manage a waste as universal waste?

    Managing wastes as universal wastes is most beneficial to small and large quantity generators of hazardous waste, or conditionally exempt small quantity generators that would otherwise be small quantity generators if they did not manage some of their wastes as universal wastes. The primary benefits of choosing the reduced management standards of the universal waste rule are that the waste does not count toward the monthly total of hazardous waste in determining generator category; the waste can be shipped without a hazardous waste manifest; the waste can be shipped by common carrier instead of a hazardous waste transporter; there are reduced notification and record-keeping requirements, and the storage time limits are less restrictive. Because universal waste does not require a hazardous waste manifest for shipment in Colorado, it is not considered hazardous waste under US Department of Transportation regulations, though other regulations may apply. State requirements for universal waste transporters are included in 6 CCR 1007-3 Part 273 Subpart D.

    What are the requirements for universal waste management?

    Categories of Universal Waste Handlers

    Under the Universal Waste Rule, persons who generate or accumulate waste batteries, pesticides, mercury containing devices, aerosol cans containing hazardous wastes, mercury-containing lamps or electronic devices and components are considered “handlers” of universal waste. [6 CCR 1007-3 Section 273.9] [Note: this definition is different from that of a generator of hazardous waste].

    There are two categories of universal waste handlers: Small Quantity Handlers and Large Quantity Handlers. A small quantity handler of universal waste is one who does not accumulate more than 5,000 kilograms of total universal at any one time. A large quantity handler of universal waste is a handler of universal waste who accumulates 5,000 kilograms or more of total universal waste. [6 CCR 1007-3 Section 273.9] In either case, a handler cannot accumulate more than 35 kilograms (about 77 pounds) of elemental mercury at one time.

    The designation of small quantity or large quantity handler of universal waste has no relationship to a facility’s hazardous waste generator status. Thus a small quantity generator of hazardous waste may be a large quantity handler of universal waste, and a facility that is a large quantity generator of hazardous waste may be a small quantity handler of universal waste. If, at any time during a calendar year, a facility exceeds the quantities for a small quantity handler of universal waste, they would be considered a large quantity handler until the next calendar year when they can reevaluate their status. [6 CCR 1007-3 Section 273.9] Labeling


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    New law bans disposal of electronic waste in landfills.

    Beginning July 1, Colorado residents no longer may dispose of most electronic waste (e-waste) in their household trash because Colorado landfills no longer may accept e-waste. The change is the result of a new law, the Electronic Recycling Jobs Act. Industry, most businesses, government agencies, institutions and schools already are subject to e-waste disposal restrictions. Read more here.